PER
CURIAM: We granted certiorari to review the Court of Appeals' decision in South Carolina Dept. of Social
Services v. M.R.C.L., 390 S.C. 329, 701 S.E.2d 757 (Ct. App. 2010). We
reverse.

FACTS

The Department of Social Services (DSS) initiated termination of
parental rights (TPR) proceedings against M.R.C.L. (mother) and R.L. (father).
Child was removed from mother and father's home in May 2007 due to allegations
of physical neglect, after both parents tested positive for crack cocaine.
Child, who was one year old at the time, was placed in a pre-adoptive foster
home with two of her siblings.[1]
Mother and father have a history with DSS dating back to 1991, and their drug
abuse is a recurring issue.

After a
merits hearing, the family court ordered
mother and father to complete a treatment plan, including a drug and alcohol
assessment and a parental assessment, and to maintain safe and appropriate
housing. Mother and father did not complete the treatment plan.

Mother
was offered job counseling services through South Carolina Vocational
Rehabilitation (SCVR), including diagnosis and treatment, GED prep classes, and
job readiness training. Although mother attended a few days of classes, she
did not successfully complete the program. Mother claimed she had
transportation issues, despite having been offered transportation to the job
training center and the GED center.

The family court also ordered mother and
father to pay child support. Father paid some child support, using disability
benefits, but mother paid none. Father and mother both considered mother to be
a "housewife," and both testified father provided for the family
financially. Father testified his income consisted of disability benefits of
approximately $689 per month and occasional income he earned by performing odd
jobs and lawn care. Because mother did not earn any income, father paid all of
the bills, and the family purchased groceries using mother's food stamps.

At the time child was removed from the home, mother and father
owned five dogs. At the time of the TPR hearing, mother and father owned ten
dogs, which mother estimated cost fifty dollars per month to feed. Mother and father also purchased cell
phones for approximately two hundred dollars. Over the course of the time
child was in foster care, these expenditures totaled over one thousand dollars.

Mother last worked in 2004 when she held three jobs in different
fast food establishments. Mother suffered from diabetes during her pregnancy
with child and later developed a degenerative disc disease in her shoulders and
lower back. According to mother, the disease left her unable to lift heavy
objects as required by many jobs in the fast food industry. At the time of the
TPR hearing mother claimed to have unsuccessfully applied for approximately
thirty jobs. On cross-examination, mother admitted this testimony differed
from testimony she had given one month earlier in a different TPR action.
Mother testified she applied for jobs not only in the fast food industry, but
also different types of jobs "to try and better [herself]." Mother
claimed to have applied for a job answering phones but believed she was not
offered the position because of her lack of computer skills.

After child was first placed in foster care, mother provided
medications and lotion for child's eczema. Mother also testified she provided
child with food, drinks, toys, diapers, and wipes. The DSS case manager
acknowledged mother provided the lotion when child was first placed into foster
care, but testified mother provided child only snacks, drinks, and toys during her
last two or three visits.

The GAL testified that, in her opinion, it was in child's best
interest to terminate mother and father's parental rights and allow the foster
parents to adopt child. The GAL stated child was reluctant to spend time with
mother and father and that they had to "bribe" child with snacks and
toys. The GAL also testified child had bonded with her foster parents and
called her foster mother "mommy." The GAL stated her biggest concern
with returning child to mother and father was that they had failed to
rehabilitate themselves from their drug use.

The
family court terminated mother and father's parental rights, generally finding
(1) mother and father willfully failed to visit the child; (2) mother and
father willfully failed to support the child; and (3) TPR was in the best
interest of the child.

Mother appealed the grant of TPR, and the Court of Appeals
reversed, holding DSS failed to prove by clear and convincing evidence that
mother willfully failed to support or visit the child. Because the Court of
Appeals found DSS failed to prove any statutory ground for TPR, it did not
reach the issue whether TPR was in the best interest of the child. We granted both
DSS and the GAL's petitions for a writ of certiorari.

ISSUE

Did the Court of Appeals err in reversing the family court's order
terminating mother's parental rights?

STANDARD OF REVIEW

Grounds for termination of parental rights must be proven by clear
and convincing evidence. Doe v. Roe, 386 S.C. 624, 630, 690 S.E.2d 573,
577 (2010). Upon review, this Court may make its own conclusion from the
record as to whether clear and convincing evidence supports the termination. Id. This Court, however, is not required to ignore the fact that the family court,
who saw and heard the witnesses, was in a better position to evaluate their
credibility and assign comparative weight to their testimony. Id.

LAW/ANALYSIS

DSS
argues the Court of Appeals erred in reversing the family court's TPR order. We agree.

The
family court may order TPR upon a finding of one or more of the following grounds,
and that terminationis in the best interest of the child:

. . . .

(3) The child has lived outside the home of either parent for a
period of six months, and during that time the parent has willfully failed to
visit the child. The court may attach little or no weight to incidental
visitations, but it must be shown that the parent was not prevented from
visiting by the party having custody or by court order. The distance of the child's
placement from the parent's home must be taken into consideration when
determining the ability to visit.

(4) The child has lived outside the home of either parent for a
period of six months, and during that time the parent has wilfully failed to
support the child. Failure to support means that the parent has failed to make
a material contribution to the child's care. A material contribution consists
of either financial contributions according to the parent's means or
contributions of food, clothing, shelter, or other necessities for the care of
the child according to the parent's means. The court may consider all relevant
circumstances in determining whether or not the parent has willfully failed to
support the child, including requests for support by the custodian and the
ability of the parent to provide support.

Whether a parent's failure to visit or support a child is
"willful" within the meaning of the statute is a question of intent
to be determined from all the facts and circumstances in each case, and the
trial judge is given wide discretion in making this determination. S.C.
Dep't of Soc. Servs. v. Broome, 307 S.C. 48, 52, 413 S.E.2d 835, 838
(1992). "While the trial judge is given wide discretion in making this
determination, the element of willfulness must be established by clear and
convincing evidence." S.C. Dep't of Soc. Servs. v. Smith, 343 S.C.
129, 137, 538 S.E.2d 285, 289 (2000). "Conduct of a parent which evinces
a settled purpose to forego parental duties may fairly be characterized as
'willful' because it manifests a conscious indifference to the rights of the
child to receive support and consortium from the parent." S.C. Dep't
of Soc. Servs. v. Seegars, 367 S.C. 623, 630, 627 S.E.2d 718, 721 (2006).

A. Willful Failure
to Visit

DSS does not challenge the Court of Appeals' holding that DSS did
not prove by clear and convincing evidence that mother willfully failed to
visit child. In finding DSS failed to show mother willfully failed to visit
the child, the Court of Appeals noted there was no evidence of how many visits
were scheduled, how many visits mother missed, how long the visits lasted, what
activities took place during the visits, how much time elapsed between each
visit, or whether mother was invited to participate in the GAL's visits. The
court further noted the record contained no evidence of the distance between
the foster home and mother's home, which the TPR statute requires to be a
consideration in determining the parent's ability to visit.

The GAL's sole argument regarding visitation is that the Court of
Appeals erred in considering whether mother was invited to participate in the
GAL's visits. The GAL does not otherwise challenge the Court of Appeals'
holding that DSS failed to show by clear and convincing evidence that mother
willfully failed to visit child.

Disregarding the Court of Appeals' consideration whether mother
was invited to participate in the GAL's visits, its holding was based on
numerous other reasons why DSS did not show mother willfully failed to visit
child. Because these rulings have not been challenged, they are the law of the
case. SeeUlmer v. Ulmer, 369 S.C. 486, 632 S.E.2d 858 (2006)
(as a general rule, an unchallenged ruling, right or wrong, is the law of the
case). We therefore decline to address whether the Court of Appeals erred in
holding DSS did not meet its burden of proving mother willfully failed to visit
child. The only issues before this Court are whether mother willfully failed
to support child and, if so, whether TPR was in the child's best interest.

B. Willful Failure
to Support

DSS argues the Court of Appeals erred in holding DSS failed to
show by clear and convincing evidence that mother willfully failed to support
the child. We agree.

The Court of Appeals found that, considering mother's
"extremely limited means," her efforts did not appear to evince a
settled purpose to forego parental duties. The Court of Appeals also noted
mother failed to take advantage of the vocational rehabilitation services
offered by SCVR, but found the programs would not have guaranteed her income,
even had she completed them.

We find the Court of Appeals erred in reversing the family court's
finding that mother willfully failed to support the child. Specifically, considering
all the facts and circumstances of this case, DSS showed by clear and
convincing evidence that mother willfully failed to support child. The TPR
statute requires the parent make a material contribution, either financial or
consisting of other necessities "according to the parent's means."
Although mother had no independent source of income, occasionally providing
child with food, drinks, medicine, diapers, wipes, and toys would not be
considered a material contribution.

The most significant issue for our consideration, therefore, is
whether mother's failure to support child was willful. We find the Court of
Appeals erred in holding DSS failed to show by clear and convincing evidence
that mother willfully failed to support child. Specifically, we disagree with
the Court of Appeals' holding that mother's failure to support child was not
willful because her actions did not evince a settled purpose to forego parental
duties. Seegars, supra. We disagree with the Court of Appeals'
conclusion that mother's failure to complete the SCVR program does not serve as
evidence that her failure to support child was willful. The Court of Appeals
correctly notes mother's completion of the program would not have guaranteed
mother an income, but would have only served to make her a more desirable
candidate for employment. However, mother's failure to increase her chances of
finding employment by taking advantage of the SCVR program or undertaking an
effort to earn her GED manifests her indifference to child and her intention to
forego parental responsibilities. Over the course of fifteen months mother had
to complete the program, she only attended a few classes. Mother's only excuse
for not completing the program was that she had transportation issues, but she
could have been provided with transportation.

Further, there is evidence mother had the means to provide child
with some financial support, but chose to spend that money on other items.
Namely, mother continued to pay an estimated fifty dollars per month to care
for her dogs during the seventeen-month span child was in foster care. This
monthly expense constituted a large sum of money mother could have instead
provided child.

In sum, we believe mother's failure to pay court-ordered child
support or give a reasonable excuse for her failure to pay manifests a
conscious indifference to the rights of child to receive support. Seegars, supra.

C. Best Interest
of the Child

DSS argues TPR is in child's best interest. We agree.

The GAL testified that, in her opinion, it was in child's best
interest to terminate mother and father's parental rights. Further, mother has
an extensive seventeen year history with DSS stemming from her recurring drug
abuse. Judging from mother's past history with drug and alcohol abuse, her
apparent indifference to obtaining gainful employment, and her lack of bond
with child, we find the family court properly found TPR was in child's best
interest.

CONCLUSION

The Court
of Appeals erred in holding DSS failed to show by clear and convincing evidence
that mother willfully failed to support child. We further hold the family
court properly found TPR was in child's best interest. Accordingly, the
decision of the Court of Appeals is

REVERSED.

TOAL, C.J., PLEICONES, BEATTY, KITTREDGE and HEARN, JJ., concur.

[1] Mother and father have a total of seven children. Excluding the child that is
the subject of this action, TPR has been granted as to five of the other
children, and one child has been emancipated.